Sanman Singh Dangi vs The State Of Madhya Pradesh on 2 February, 2026

NEUTRAL CITATION NO. 2026:MPHC-GWL:4363

1 MCRC-13170-2021
IN THE HIGH COURT OF MADHYA PRADESH
AT GWALIOR
BEFORE
HON'BLE SHRI JUSTICE RAJESH KUMAR GUPTA
ON THE 2 nd OF FEBRUARY, 2026
MISC. CRIMINAL CASE No. 12778 of 2021
SANMAN SINGH DANGI AND OTHERS
Versus
THE STATE OF MADHYA PRADESH AND OTHERS
Appearance:
Shri Divakar Vyas - Advocate for the petitioner.

Shri Dheeraj Kumar Budholiya- Advocate for respondent No.2.
Shri Anurag Sharma - PP for the State.
WITH
MISC. CRIMINAL CASE No. 13170 of 2021
SANMAN SINGH DANGI AND OTHERS
Versus
THE STATE OF MADHYA PRADESH AND OTHERS
Appearance:
Shri Divakar Vyas - Advocate for the petitioner.
Shri Dheeraj Kumar Budholiya- Advocate for respondent No.2.

Shri Anurag Sharma - PP for the State.

ORDER

Since both these petitions have been preferred under Section 482 of the Code of Criminal Procedure and arise out of criminal proceedings initiated by close family members against the same set of accused persons, involving overlapping facts and similar legal issues, they are being heard and

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2 MCRC-13170-2021 decided by this common order.

Facts of M.Cr.C. No.12778/2021

2. The prosecution case, in brief, is that respondent No.2, who is the wife of petitioner No.3 and daughter-in-law of petitioner Nos.1 and 2, lodged a report alleging that on 26.07.2019 at about 08:00 PM , the petitioners assaulted her, caused injuries and abused her. On the basis of the said report, Crime No.397/2019 was registered at Police Station Kotwali, District Vidisha. After due investigation, the police filed a charge-sheet against the petitioners.

3. Learned counsel for the petitioners submits that the FIR has been lodged falsely due to matrimonial discord between respondent No.2 and petitioner No.3. It is argued that respondent No.2 had earlier filed a

complaint under Section 498-A IPC and Section 4 of the Dowry Prohibition Act, which came to be dismissed vide order dated 04.01.2018 .

4. It is further contended that a Panchanama was earlier drawn in the presence of respectable persons of society, wherein it was decided that respondent No.2 and her husband would live separately and that other family members would not interfere. According to the petitioners, the present FIR is nothing but an abuse of the process of law.

5. Heavy reliance has been placed on the fact that on 27.07.2019 , respondent No.2 lodged another FIR at Crime No.399/2019 alleging offences under Sections 354, 354-A, 354-D and 506 IPC against petitioner No.1. It is contended that since such allegations were not mentioned in the present FIR dated 26.07.2019, the same clearly reflects an afterthought.

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6. It is also pointed out that petitioner No.3 lodged an FIR at Crime No.402/2019 against the father of respondent No.2 alleging abuse and intimidation. On the aforesaid grounds, quashment of the FIR and all consequential proceedings has been sought.

Facts of M.Cr.C. No.13170/2021

7. In this petition, the FIR has been lodged by respondent No.2, who is the sister-in-law (Bhabhi) of petitioner Nos.3 and 4 and daughter-in-law of petitioner Nos.1 and 2. It is alleged that for about six years prior to 26.07.2019 , all the petitioners subjected her to cruelty.

8. It is further alleged that her husband Rahul expired in an accident on 28.06.2019 , and thereafter petitioner No.2 outraged her modesty about fifteen days prior to the incident. On 26.07.2019 , when she was alone in her room, petitioner No.3 allegedly attempted to outrage her modesty, and the other petitioners supported him.

9. On the basis of the aforesaid allegations, Crime No.412/2019 was registered at Police Station Kotwali, District Vidisha on 02.08.2019 , and after investigation, a charge-sheet has been filed against the petitioners.

10. Learned counsel for the petitioners submits that the FIR has been lodged with mala fide intention on account of property disputes. It is argued that the cousin sister of respondent No.2, who is married to petitioner No.3, also lodged a similar FIR at Crime No.399/2019 alleging sexual assault against petitioner No.1, which shows a concerted attempt to falsely implicate the entire family.

11. It is contended that the allegations are absurd, inherently

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4 MCRC-13170-2021 improbable and motivated by an intention to grab the agricultural land of the petitioners and, therefore, the FIR and consequential proceedings deserve to be quashed.

12. The principal contention advanced on behalf of the petitioners in both matters is that the criminal proceedings are manifestly attended with mala fides and amount to an abuse of the process of law. It is argued that earlier complaints lodged by the complainants have either been dismissed or have resulted in acquittal, and therefore, the present proceedings deserve to be quashed.

13. Learned counsel for the State, on the other hand, submits that the FIRs disclose commission of cognizable offences, investigation has been completed, charge-sheets have been filed and the matters are at the stage of trial. It is contended that disputed questions of fact cannot be adjudicated in proceedings under Section 482 Cr.P.C.

14. Heard counsel for the rival parties and perused the entire record with due care.

15. The scope and ambit of the inherent powers under Section 482 Cr.P.C. is no longer res integra. In State of Haryana v. Bhajan Lal , 1992 Supp (1) SCC 335, the Supreme Court has laid down illustrative categories where quashing of criminal proceedings may be justified. At the same time, the Court has cautioned that such power should be exercised sparingly and in the rarest of rare cases.

16. In Amit Kapoor v. Ramesh Chander , (2012) 9 SCC 460, the Supreme Court has held that at the stage of quashing, the High Court should

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5 MCRC-13170-2021 not conduct a meticulous examination of evidence or evaluate the correctness of the allegations, and that where the allegations disclose a prima facie offence, the proceedings should not be scuttled at the threshold.

17. Recently, in Neeharika Infrastructure Pvt. Ltd. v. State of Maharashtra, (2021) 6 SCC 821, the Supreme Court has reiterated that the High Court should not interfere with criminal proceedings merely because the allegations appear to be motivated or because the accused has a plausible defence. It has been categorically held that the truthfulness, sufficiency or reliability of the allegations is a matter for trial.

18. Tested on the anvil of the aforesaid principles, this Court finds that in both the present cases, the FIRs and charge-sheets contain specific allegations against the petitioners. Whether the allegations are exaggerated, false or motivated by matrimonial or property disputes, are matters which can only be decided after appreciation of evidence during trial.

19. The contention of the petitioners that earlier complaints lodged by the complainants resulted in acquittal or dismissal does not advance their case. Mere acquittal in earlier cases does not ipso facto render subsequent proceedings illegal or vexatious, particularly when the offences alleged are distinct and arise out of separate factual matrices.

20. From perusal of the record, it is evident that the earlier cases filed by the respondent/complainant and the present cases pertain to different incidents and different sections of IPC. The defence of false implication, previous enmity, or mala fide intention is a matter of defence, which cannot be examined in proceedings under Section 482 Cr.P.C.

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21. In view of the aforesaid, facts and circumstances of the case, this court does not find merits in the present petitions. Hence, the petitions fails and are hereby dismissed.

(RAJESH KUMAR GUPTA ) JUDGE

Vishal